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### Schaffner, Karen S.

From: Textor, Marise L. [Marise.Textor@tpcgrp.com] Sent: Friday, December 17, 2010 5:47 PM To: Schaffner, Karen S.; Shedd.Steve@epamail.epa.gov Cc: Nidini, Kelly J.; Stan Hayes Subject: RE: RTR MVL: review of TPC 12Oct2010 data sets Attachments: TPC.Corr Lat-Lon.xlsx

Dear Steve and Karen –

Please see the responses to the questions in your e mail of November 15 below, in blue font. If you have any additional questions, please do not hesitate to call me or ema il to me at any time. Although I will be on vacati on for the next two weeks, I will be monitoring my email and will try t o respond to anything from you over the holiday vac ation within a few days.

I wish you all a very happy holiday and wonderful N ew Year.

Best regards, Marise



### Marise Lada Textor, P.E. Corporate Director - Regulatory Affairs marise.textor@tpcgrp.com TPC Group | www.tpcgrp.com Office: 713.840.2410 | Cell: 713.703.8245 | Fax: 281.271.4506 5151 San Felipe, Suite 800 | Houston, Texas 77056

From: Schaffner, Karen S. [mailto:ksschaffner@rti.org] Sent: Monday, November 15, 2010 2:18 PM To: Textor, Marise L.; Chu, Celia; Nidini, Kelly J. Cc: Shedd.Steve@epamail.epa.gov Subject: RTR MVL: review of TPC 12Oct2010 data sets

Dear Marise and Celia: Thank you for providing th e revised data sets for TPC Houston TX on 12 Oct 20 10. We have reviewed the files and have several follow-up quest ions, to make certain we understand the information you sent, and a few ideas for next steps. Please contact Steve She dd with EPA or me to discuss any questions. Thank you, Karen.

Review of TPC dataset Excel files sent on 12Oct2010 :

Reviewed files : FromTPC_2010Oct12_2005 NEI.Marine Term.TPC.xlsx FromTPC_2010Oct12_2005 NEI.Marine Term.TPC.xlsx From TPC_2010Oct12_2005 NEI Marine Term TPC (js) wi th 2009 data.xlsx

Am returning files : FromTPC_2010Oct12_2005 NEI.Marine Term.TPC_kss.xlsx From TPC_2010Oct12_2005 NEI Marine Term TPC (js) wi th 2009 data_kss.xlsx TPC_2010Nov12_Image1.jpg TPC_2010Nov12_Image2.jpg2 **MVL Records** :

1. What is the difference between files “2005 NEI.Mari ne Term.TPC.xlsx” and “2005 NEI.Marine Term.TPC.xls x”? It appears that both files “2005 NEI.Marine Term.TPC.x lsx” have coordinate changes and one stack paramete r correction in the file, and are the same file (i.e. , duplicate file). There didn’t appear to be any o ther changes. Please confirm. Yes, these two files are the same. The same email and the associated attachment from James Scroggins dated August 11, 201 was attached twice in an email to St eve Shedd on October 12, 2010. I apologize for the confusion.

2. There were 4 records for MVL operations in the orig inal 2005 NEI dataset and also in “FromTPC_2010Oct12_2005 NEI.Marine Term.TPC.xlsx”. In June, TPC mentioned that Methanol emissions wer e from “unloading”, not loading, so please confirm. Methanol is only unloaded at the TPC marine loading facility.

3. The Process_MACT_Code field is entered as 1501 for the whole data set (this is the MACT code for HON). The 3 (or 4) records for MVL should be 0603 (this is the MACT code for Marine Vessel Loading Operations). P lease confirm that this change should be made. Yes, the change should be made.

**Total Facility Records:**

4. There were 89 records for the facility in the origi nal 2005 NEI data set sent to TPC in June 2010; the corrected data set has 59 records. Which records were droppe d/deleted, and why? It appears that EMISSION_UNIT 0193 was dropped beca use all of the HAPs listed in the original table we re essentially zeros (i.e., 9.04E-08), accounting for 31 deleted entries. However, the corrected data se t has two duplicate entries for EMISSION_UNIT 0158, thus brin ging the total to 59 (89 – 31 deleted + 1 duplicate = 59)

5. There were 32 records for the facility related to B oilers, Process_MACT_Code field 107-2, that appear to have been deleted/dropped from the data set for the faci lity. These records include those for Emission_Uni t 0193; Process_ID 0073; SCC 10200601; Emission_Release_Poi nt_ID 0204. Could you confirm why? Please refer to the response to question No. 4 – 31 were essentially zeros and 1 was a duplicate, th us totaling 32 deleted or dropped records.

6. There were 2 records for Emission_Unit 0158; Proces s_ID 0068; SCC 40899999; Emission_Release_Point_ID 0167 in the original data set (original had 1,3-but adiene emissions of 0.09 ton; and MTBE emissions of 0.2961 ton). 2 more records were added for this emission point; the new records appear to be duplicates of t he original. Please confirm that these are meant to b e added. They were duplicate entries and, therefore, do not need to be added. Please delete them.

7. It appears that all coordinate data have been corre cted. Our GIS person checked the coordinate data f or all 59 records. It looked like several emission points ar e outside the facility boundary, as we understood t he facility boundaries from earlier conversations. The attache d file called “FromTPC_2010Oct12_2005 NEI.Marine Term.TPC_kss.xlsx” contains an additional field to the far right of the worksheet called “OUTSIDE_PROPERTY_ID”, with a number key to the plo tting of those points on the attached file “TPC_2010Nov12_Image1.jpg”. Approximately 18 reco rds looked like they are outside the facility bound aries. Could you check on these points and address any pro blems? It appears that PC_2010Nov12_Image1.jpg is based on the uncorrected coordinates. We are attaching a new file to this email with corrected coordinates, TPC.Corr Lat-Lon.xlsx. To assist in incorporating the corre cted3

information, we have put it in a format similar to the one used by HEM-3 (EPA’s risk model) to specify source locations. This should make use of the corrected d ata straightforward. Column U in EPA’s file corres ponds to the numbers (without the letters “ID”) in column A of the new attached file.

8. It appears that the coordinates for the 4 MVL emiss ion points are off a bit from where we expected the m. For example, J.Scroggins sent a 2010June03 email with c oordinates of Latitude 29.717762152834343, Longitud e - 95.24133682250976. These are somewhat different fr om those provided in the latest file: -95.241944, 29.716388 for the Emission_Release_Point_ID 0070 an d -95.241944, 29.716666 for Emission_Release_Point_ ID 0218. In looking at the map where the docks and va por processer actually are, they look a bit off (Se e map key numbers 19, 20, 21, 22). Please advise which are c orrect. James sent one corrected point (latitude and longit ude) in June. We recommend that EPA use this sing le corrected location from James for the dock emission points, which will result in a much more accurate location than EPA’s current coordinates for dock emission po ints. Nonetheless, due to the heavy industrialized surrounding area, the precise location of these doc k points will not affect the final result significa ntly.

9. It looks like the stack parameters for one record h ave been corrected (Emission_Unit 0066; Process_ID 0057; SCC 30119799; Emission_Release_Point_ID 0051), and for all other emission points, the stack parameters are correct as is. Could you please confirm this. Our comparison of the two files does not show any d ifference in parameters; please identify which para meters you are speaking about so that we can check again.

10. What is the significance of the SCC titles in Red t ext and yellow highlight in file “2005 NEI Marine T erm TPC (js) with 2009 data.xlsx” and the SCC titles in Red text and yellow highlight in file “FromTPC_2010Oct12_20 05 NEI.Marine Term.TPC.xlsx”? These were indicated in yellow highlights and red t ext because they were large sources and incorrectly located in the community and therefore would be risk driver s in EPA’s original (and incorrect due to incorrect coordinates) risk analysis. The yellow highlights and red text were internal convenience notations an d not necessarily meant for EPA information. We apologiz e for any confusion

.

What is the field name for the values in column B o f the “2005 NEI Marine Term TPC (js) with 2009 data .xlsx” spreadsheet – is it “Emission_Release_Point_ID”? Yes, this is “Emission_Release_Point_ID”.

New values of 1,3-butadiene are suggested for 9 rec ords. If you suggest that emissions data for 2009 are more representative of pl ant operation, then we need to create a full facili ty data set with the 2009 emissions data, as well as a full data set for 2005 emissions. The 2009 data are representative of current operati on. TPC does not intend to increase emissions of 1 ,3- butadiene. As discussed during the EPA visit to TP C, under a voluntary emissions reduction agreement (VERA) with the State of Texas, we have invested significa nt capital expenditures and made significant change s in our operating practices and culture, resulting in a 75 percent reduction in emissions of 1,3-butadiene, pl ant-wide, since our baseline year of 2004.

The reason that TPC only provided the 1,3-butadiene information is that 99 percent of the risk resulte d from emissions of 1,3-butadiene. The only other two com pounds in the NEI are chromium compounds and MTBE. EPA should be able to see a similar relationship in their 2005 analysis, for confirmation.

Karen Schaffner Air Quality Engineering Group RTI International 3040 Cornwallis Rd (800 Park, C311) Research Triangle Park, NC 27709 phone: (919) 316 3740 fax: (919) 541 7155MTextorTPC-2010Dec17_TPC.Corr Lat-Lon.xlsx TPC Corrected Lat-Lon Source ID Location type (U=UTM, L=lat/lon) Longitude (decimal) or UTM East (m) [use center for point or volume sources, SW

corner for area sources] Latitude (decimal) or UTM North (m) [use center for point or volume sources, SW corner for area sources]
ID01 L -95.262953 29.697958
ID02 L -95.262953 29.697958
ID000004 L -95.249064 29.698235
ID000016 L -95.256564 29.697958
ID000017 L -95.256286 29.69768
ID000018 L -95.256564 29.69768
ID000019 L -95.256564 29.69768
ID000023 L -95.255731 29.69768
ID000051 L -95.255453 29.694624
ID000054 L -95.252953 29.699624
ID000064 L -95.254064 29.696013
ID000070 L -95.241337 29.717762 MTVLO Source
ID000097 L -95.254064 29.699624
ID000127 L -95.255731 29.697958
ID000166 L -95.252397 29.695735
ID000167 L -95.253508 29.694902
ID000168 L -95.254064 29.69768
ID000171 L -95.254342 29.699069
ID000207 L -95.253508 29.694902
ID000209 L -95.253508 29.694902
ID000210 L -95.256008 29.697402
ID000211 L -95.255731 29.699347
ID000214 L -95.249897 29.699069
ID000218 L -95.241337 29.717762 MTVLO Source
ID000224 L -95.249897 29.698513
ID000225 L -95.249619 29.698235
ID000227 L -95.253786 29.698513
ID000228 L -95.255175 29.697958
ID000232 L -95.241337 29.717762
ID000236 L -95.255175 29.696569
ID000237 L -95.252675 29.697402
ID000238 L -95.252397 29.698235
ID000240 L -95.255175 29.697402
ID000241 L -95.255175 29.697124

NOTES: HEM-3/AERMOD Emission Location File Format (first four columns) Yellow shading/red text denotes corrected latitude/longitude values Blue shading indicates MTVLO source